RBOA’s Submission to CRT Commissioners

28 February 2025

The Residential Boat Owners’ Association (RBOA) was founded in 1963, It is a national organisation. We are regularly consulted by HMG departments, Local Authorities, Citizens Advice and law firms on all matters to do with residential boating in all its forms particularly with regard to moorings planning issues and disputes between boaters and moorings owners and operators.

We welcome the CRT initiative to appoint a commission to investigate/advise/inform their (CRT’s) licensing regime. Our support is, however, subject to several caveats.

  1. The commissioners do not regard the Terms of Reference (ToR) as proscriptive and go where the evidence they collect takes them.
  2. We expect the commissioners to take evidence from the various relevant user groups, much in the style of a Parliamentary Select Committee
  3. We expect the commissioners to challenge CRT to provide evidence for the assertions which they have made within the ToR

A specific issue which the RBOA hope the commissioners will challenge is CRTs insistence that continuous cruisers who are unable to comply with the rules under which the licences are issued obtain a home mooring. To say this is disingenuous is being polite. CRT are well aware that if a boater is living on their boat, on a mooring, that mooring must have residential planning approval. Such moorings are in hens’ teeth territory. By this policy CRT are knowingly forcing boaters to escape from the pressure and bureaucracy of their staff only for them to have a similar level of grief from a moorings operator/ Local Authority. You might imagine the remedy would be for the boater/owner of the mooring to apply for change of use of the mooring from leisure to residential, sadly, most planning applications for residential moorings are refused.

Whilst we are pleased CRT are suggesting a speedy conclusion for this exercise, we are concerned that an unintended consequence is that the need for speed means the commissioners are precluded from applying the rigour they will need to obtain and then verify the information which will, inevitably, be required from CRT.

This exercise does have the support and goodwill of the RBOA however, all parties should be aware that the average liveaboard/residential boater is hugely sceptical most believing that CRT have appointed three patsies to confirm the plans that CRT have already developed. We can only hope that commissioners will take evidence from the boating community and give due weight to the concerns and aspirations of those of us whose boats are also our homes.

We ask the commissioners to bear in mind that the number of boats being used as a “primary residence” is growing. Many of these are new build, or relatively new, built and maintained to a high standard with owners who are financially secure. However, every navigation authority is seeing a significant rise in the numbers of people who have found a boat which is marginally better than a cardboard box in a shop doorway in which the occupants are just trying to survive. This cohort must not be forgotten or further marginalised. The RBOA would like to see funding hypothecated to provide the resources for welfare and administrative support to directly assist these boaters and liaise with the relevant support services in local authorities and the NHS.

If there is a hierarchy of need on the waterways those of us who live in our boats are at the top of that tree. By definition we are on the water 24/7, the waterway is our home. For a substantial percentage of us this is no longer a choice, the escalation in property prices both to buy or rent precludes us from ever returning to bricks and mortar.

We are aware that there are some who believe those of us who live on our boats on CRT waters and without a mooring are getting a good deal at the expense of the rest of the waterways community. That is difficult to square with the facts.  Our licence fee, now at a premium because we don’t have a home mooring, grants us no additional services or privileges. CRT assert, without evidence, we somehow cost them more.

However, Robin Evans CRTs first CEO told the author of this document that continuous cruisers saved CRT money on maintenance because our navigating in the off season helped to prevent silting, particularly of lock gates.  In addition, he said, we noticed and reported, problems that were at the time relatively minor but that would otherwise go unnoticed, possibly for months, and consequently become much more serious and therefore more expensive to remedy. CRT should be challenged to explain what has changed or provide evidence that demonstrates Robin was wrong.

Continuous cruisers are denied privileges accorded to the rest of society for example, bus passes. Many were excluded from the Energy Bills Support scheme. It is increasingly difficult to find functioning black water disposal facilities, and dry waste facilities are being withdrawn. Most worrying is the lack of maintenance on, and therefore the loss of, freshwater taps.

If the Commissioners decide that they agree those of us who live on boats should pay a premium, then at least grant us something in return. Perhaps the right to moor for extended periods on 14 day moorings. Institute a scheme whereby those who meet the age requirement could be granted a bus pass. Instruct CRT to develop a mechanism whereby Government Grants such as the Energy Support Scheme reaches all liveaboard boaters irrespective of their mooring status.

Finally, we ask the commissioners to be aware that whilst their sponsor is CRT every other Navigation Authority in the UK will read the conclusions of their report with great interest and will wonder if the policies described are ones they should adopt.  Your responsibility goes well beyond CRT waters thousands, potentially tens of thousands, of lives could be impacted by your conclusions.